ML13347B286

Summary of Public Meeting Webinar Regarding Independent Spent Fuel Storage Installation (ISFSI) Basics

ML13347B286
Person / Time
Site:	Palisades
Issue date:	12/13/2013
From:	Jamie Benjamin Reactor Projects Region 3 Branch 4
To:	Entergy Nuclear Operations
References
Download: ML13347B286 (9)

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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 December 13, 2013 LICENSEE:

Entergy Nuclear Operations, Inc.

FACILITY:

Palisades Nuclear Plant

SUMMARY

OF THE NOVEMBER 14, 2013, PUBLIC MEETING WEBINAR REGARDING INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

BASICS On November 14, 2013, the U S. Nuclear Regulatory Commission (NRC) held a two part Public Meeting webinar to discuss NRCs perspectives on ISFSIs. During the first part of the meeting, the NRC staff presented an overall discussion regarding the basics of ISFSI design and operation. Enclosure 1 is a list of attendees at the meeting. Copies of the slides used by the NRC staff during the meeting can be accessed through the NRCs Agency wide Document Access and Management System: ADAMS (ML13322A400).

The NRC staff stated in the opening remarks that the second part of the meeting was geared towards answering follow up questions from the public about ISFSI. There were 77 meeting participants that had the opportunity to submit questions to the NRC staff about ISFSIs through the Webinar process. In addition to answering questions from members of the public on November 14, NRC representatives agreed to provide an answer to technical questions regarding the topic of ISFSIs that were submitted during the meeting, but were not answered during the allocated meeting time. The answers to these questions are included in the meeting summary (Enclosure 2). A recording of the webinar can be accessed through ADAMS (ML13338A348). Please note that this recording will take additional time to download because of the large file size. The recording can be accessed on the second page of the PDF document by clicking on the forward arrow located on the bottom left corner.

Sincerely,

/RA/

Jamie Benjamin, Acting Chief Branch 4 Division of Reactor Projects Docket Nos. 50-255 and 72-007 License No. DPR-20

Enclosures:

1. Public Meeting Principal Attendees

2. Questions for the NRC Meeting on November 14, 2013 cc w/encls: Distribution via ListServTM

PUBLIC MEETING PRINCIPAL ATTENDEES November 14, 2013 NRC Attendees A. Boland, Acting Deputy Regional Administrator, RIII J. Giessner, Acting Director Division of Reactor Safety, RIII J. Benjamin, Acting Chief, Division of Reactors Projects Branch 4, RIII M. Learn, Reactor Engineer, Division of Nuclear Materials Safety, RIII R. Edwards, Reactor Inspector, Division of Nuclear Materials Safety, RIII

1 Questions for the NRC Meeting on November 14, 2013

1. About how much does one loaded cask weigh?

A Ventilated Storage Cask (VSC) -24 cask system with a loaded Multi-Assembly Sealed Basket (MSB) canister weighs approximately 135 tons. A Transnuclear (TN) Nutech Horizontal Modular Storage (NUHOMS) Horizontal Storage Module (HSM) with a loaded Dry Shielded Canister (DSC) weighs approximately 330 tons.

2. Roughly what is the capacity of the existing casks/how long will it take before they are filled, and additional casks will need to be built?

The licensee procures casks as they are needed and does not routinely keep empty casks on site. At the Palisades facility, the following storage systems have been utilized for storage: VSC-24 storage system and TN NUHOMS storage system. The VSC-24 cask system allows storage of up to 24 pressurized water reactor spent fuel assemblies in each cask. For the TN NUHOMS system either 24 high burn-up or 32 moderate burn-up pressurized water reactor fuel assemblies are allowed for storage Horizontal Storage Module.

3. The webinar speaker stated that dry storage canisters are tested (dry-run) for loading and unloading activities with empty canisters, or with dummy fuel assemblies. Have any dry storage canisters loaded with actual used fuel been removed from their horizontal storage module (HSM)?

Several licensees have unloaded spent fuel from an ISFSI. For example, the Surry Power Station and the Peach Bottom Atomic Power Station have unloaded spent fuel from TN-68 and CASTOR V/21 casks respectively.

4. Palisades dry casks are located as close as 150 yard, or less, from the waters of Lake Michigan. Arent they at dire risk of a terrorist attack from the lake itself? Such as from a TOW anti-tank missile fired from a speed boat? NRCs security regulations dont worry about such scenarios, right?

The NRC has thoroughly analyzed and assessed credible threat scenarios to ensure plant security. In order to determine how much physical protection is enough, the NRC monitors intelligence information to keep abreast of foreign and domestic events and remains aware of the capabilities of potential adversaries. We use this information, and other sources, to ensure nuclear plants and other NRC regulated facilities remain safe and secure. We cannot provide an answer to your question because most of the threat analysis work is not publicly available.

5. At Palisades, both dry cask storage pads are in violation of NRC earthquake safety regulations, both liquefactions regulations (older pad) and transmission regulations (new pad). NRC dry cask storage inspector Dr. Ross Landsman, now retired, was assured by NRC Region 3 that the older pads dry casks would be moved to the newer pad, given the older pads NRC earthquake safety regulation violations. But the newer pad also violates NRC earthquake safety regulations. How can NRC allow this major safety violation, so close to Lake Michigan? The older pad is just 150 yards, or closer, to Lake Michigan waters. Lake Michigan is the drinking supply for tens of millions of people. How can NRC allow such risks?

2 Both ISFSI pads at the Palisades Nuclear Plant are safe and in compliance with NRC safety requirements. Specifically, the NRC has determined that the ISFSI pads have been designed to adequately support the static and dynamic loads of the stored casks during an earthquake.

During the construction of the first ISFSI pad at Palisades, questions were raised by NRC staff and interested members of the public regarding the possible effects of earthquakes on soil liquefaction, wind and wave effects on ground erosion, and the effects of these phenomena on the ISFSI pad and the spent fuel storage casks. The licensee performed additional analysis on the effects of soil erosion, including the effects of high lake waves, wind, and rain on the ISFSI pad. In addition, the licensee analyzed the effect of a safe shutdown earthquake on soil and foundation stability, based on both existing soil data and new data acquired from additional soil borings taken in response to the questions regarding the stability of the pad site. The results of the licensee analysis showed that the pad can support the casks safely.

The NRC independently analyzed the soil liquefaction effects on pad integrity, the pad design and construction, and the stability of slopes surrounding the pad to determine both the long-term effects of erosion under normal conditions and the effects of a postulated earthquake. This independent NRC analysis also concluded that the ISFSI pad will adequately support the cask as required by NRC regulations. The NRC independent assessment of the licensee analysis is documented in the "Independent NRC Staff Final Safety Assessment of the Dry Spent Fuel Cask Storage Facility at Palisades Nuclear Power Plant Site," dated September 20, 1994 [ADAMS ML060480230].

Additional information regarding the first ISFSI at Palisades can be found in Information Notice 95-28, Emplacement of Support Pads for Spent Dry Storage Installations at Reactor Sites [ADAMS ML031060295].

The NRCs inspection of the second ISFSI pad is initially documented in Inspection Report 07200007/2004-002 [ADAMS ML042510075]. The NRCs resolution of the subsurface bearing stability beneath the ISFSI pad was documented in inspection report 0500255/2006-013 [ADAMS ML070240635]. The NRCs resolution of the translation of the safe shutdown earthquake for the reactor site to the ISFSI pad is documented in inspection report 05000255/2006-002 [ADAMS ML061350371].

6. The dry cask storage pad at Palisades, the older one near the lake, it is located on top of 55 feet of loose sand, anchored to nothing. As NRCs former dry cask storage inspector for Region 3, Dr. Ross Landsman, has warned, that sand dune could open up in an earthquake. The lake could fill the void. Casks could fall into the breach.

Water could infiltrate the casks. A nuclear criticality could be sparked, given the fissile material still in the high-level radioactive waste. Why has NRC allowed such risks to go on?

The NRC has determined that the ISFSI pads have been designed to adequately support the static and dynamic loads of the stored casks, considering potential amplification of earthquakes through soil-structure interaction, and soil liquefaction potential or other soil instability due to vibratory ground motion. Both ISFSI pads at the Palisades Nuclear Plant are in compliance with NRC safety requirements. Please review the response to Question 5. Based on the information provided above, the scenarios that are described in this question are non-credible.

3

7. The horizontally oriented bunker shaped dry casks on the newer pad at Palisades, what about whistleblower revelations that the cradle holding the inner canister is vulnerable to corrosion? What about the seismic risks of this?

The inner canister support structure is not vulnerable to corrosion since the Dry Shielded Canister support structure in the Horizontal Storage Module is coated with a non-corrosive material and, therefore, requires no additional protection against the expected environment.

Additionally, the Horizontal Storage Module heat shield is coated for corrosion protection.

Transnuclear has performed an analysis demonstrating that during a worst case seismic event, with additional safety margin at Palisades, a loaded canister stored within a Horizontal Storage Module will be supported. Therefore, there is no additional seismic risk.

8. Why dont dry casks have to have temperature, radiation, or pressure monitors?

Couldnt a loss of inerting gas go unnoticed for a period of time, leading to fuel corrosion and overheating due to loss of inerting gas? Couldnt a radiation leak go unnoticed? Couldnt an overheating incident go unnoticed?

Welded canisters do not require any instrumentation to assure the safe storage of spent fuel because there are no long-term degradation mechanisms that could cause the closure welds to fail within the design lifetime of the canister, and because the possibility and effects of corrosion have been considered in the canister confinement boundary design. Licensees are required to perform a daily surveillance of the passive heat removal system to ensure it is operating as required.

9. You make dry casks sound invulnerable to any theat. But what about a meteor, could they withstand that? Less unlikely than a meteor, what about a tornado missile?

A 2 mile tornado leveled the town of Joplin, Missouri. What if such a tornado hit a dry cask storage pad, hurling telephone poles or other objects into the dry casks? What about a storm with 200 miles per hour winds, like just hit the Philippines? What about such high wind risks impacting a storage pool, which arent even located within robust radiological containment structures?

The casks are designed to withstand loads associated with the most severe meteorological conditions, including extreme wind and tornado, which are postulated to occur at the storage site. Tornado design parameters used to evaluate the suitability of the cask include high winds, wind generated pressure differentials and tornado generated missiles. Typically, the design basis tornado maximum wind speed is approximately 360 mph.

The casks are designed to withstand the effects of postulated tornado-generated missile impacts in accordance with NRC guidance. These missiles consist of a massive, high kinetic-energy missile that deforms on impact, a rigid missile to test penetration resistance, and a small rigid missile of a size sufficient to just pass through any openings in protective barriers. All missiles are assumed to impact in a manner that produces the maximum damage to the cask. Such calculations indicate that the casks will remain upright following the event, and that loads associated with this impact do not compromise the integrity of the cask.

4

10. You talk so confidently about unloading storage casks into transport casks. But Palisades has never demonstrated a safe unloading procedure. In fact, Palisades admitted that a cask loaded in June 1994 had defective welds. To live up to its word, that it would unload casks if any problems developed, Consumers Energy pledged to unload that defective cask #4. That was over 19 years ago. It seems Palisades has a problem unloading its dry casks, wouldnt you agree?

Cask No. 4 was initially loaded with spent fuel at the Palisades plant in 1994. Following cask loading reviews by licensee and vendor inspectors of radiography test inspection films three indications were identified in longitudinal seam weld of cask No. 4. The licensee performed an engineering evaluation of the three indications with respect to the operability of cask No. 4 and determined that despite the flaws, the pressure and containment functions were maintained in accordance with the design basis and that the cask is structurally sound.

In addition, the licensee performed radiation surveys which indicated that there was no change in radiation levels that would indicate fission gas protrusion through the basket wall.

The NRCs staff independently reviewed the licensees evaluation and determined that cask No. 4 will be able to perform its intended function. The calculations confirmed that the cask shell material demonstrated a considerable flaw tolerance and calculations indicated that the three indications will not propagate either during normal operations or accident scenarios. Thus, cask No. 4 does not pose an increased radiological impact to the public or environment. The details of the NRCs evaluation can be found in a Technical Assistance Request [ADAMS ML100210186].

In 1994, the licensee revised the procedure for safe unloading after they identified several technical issues. The NRC inspectors reviewed the procedure and determined that the licensee would be able to safely unload a cask. In 1997, the licensee informed the NRC that Cask No. 4 will not be unloaded until it could be loaded into a certified storage and transportation cask in preparation for permanent disposal.

11. If spent fuel pool in an ISFSI facility were to be removed to a consolidated spent fuel storage site, what equipment, facilities, and personnel would be needed? Is it practical to move fuel to a temporary site than then again to a permanent site? Rent costs and worker exposure and handling and transport risks unnecessarily multiplied?

Removal of spent fuel from an ISFSI to a consolidated interim storage facility would require shipment in a certified transportation cask. Although some dual purpose storage casks are certified for both storage and transportation, a casks certification for storage does not necessarily also allow the cask to be certified for transportation. As such, some fuel would be required to be unloaded prior to shipping.

If fuel unloading would be required to place the fuel into a certified transportation cask, the licensee could perform that operation in the sites spent fuel pool.

The licensed facility is responsible for the financial cost associated with these activities.

However, the NRC will ensure any storage, packaging and transportation activities are done safely and in accordance with NRC requirements.

5

12. That does not answer the question about blockage. In an emergency on the order of Fukushima, there was no guarantee that personnel could have intervened effectively if those vents got blocked. If Forth Calhoun went under any more water the same situation would have existed. So the question stands - HOW long before the canister overheats, and fuel damage occurs? If you have not done that calculation, youre doing the same assuming that the Courts said are not acceptable in the waste confidence docket.

Couldnt blowing sand at Palisades block the bottom vent on dry casks, causing overheating of the stores irradiated fuel?

The casks and modules are analyzed for complete inlet vent blockages for a discrete time period of 30 and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> respectively rather than until fuel damage occurs. The analyses assume the ambient atmospheric temperature is 100 and the casks contain fuel with the maximum heat loads permitted for storage, while in reality the actual loaded fuel contains significantly less decay heat. These analyses have concluded that even if all inlets were completely blocked, all of the system components will remain well below their accident temperature limit over a one-day period. For this reason, a daily interval is established for visual inspection of the cask inlet ducts, as required by cask technical specifications.

Blowing sand, snow, or other debris could potentially block vents of the storage casks and modules. The thermal performance of the cask and Horizontal Storage Module systems are verified by the licensee through daily visual inspections of the inlet and outlet ducts that are performed to detect and prevent any airflow blockages. The daily visual inspections ensure that the temperatures of all system components remain within their analyzed thermal design limits.

December 13, 2013 LICENSEE:

Entergy Nuclear Operations, Inc.

FACILITY:

Palisades Nuclear Plant

SUMMARY

OF THE NOVEMBER 14, 2013, PUBLIC MEETING WEBINAR REGARDING INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

BASICS On November 14, 2013, the U S. Nuclear Regulatory Commission (NRC) held a two part Public Meeting webinar to discuss NRCs perspectives on ISFSIs. During the first part of the meeting, the NRC staff presented an overall discussion regarding the basics of ISFSI design and operation. Enclosure 1 is a list of attendees at the meeting. Copies of the slides used by the NRC staff during the meeting can be accessed through the NRCs Agency wide Document Access and Management System: ADAMS (ML13322A400).

The NRC staff stated in the opening remarks that the second part of the meeting was geared towards answering follow up questions from the public about ISFSI. There were 77 meeting participants that had the opportunity to submit questions to the NRC staff about ISFSIs through the Webinar process. In addition to answering questions from members of the public on November 14, NRC representatives agreed to provide an answer to technical questions regarding the topic of ISFSIs that were submitted during the meeting, but were not answered during the allocated meeting time. The answers to these questions are included in the meeting summary (Enclosure 2). A recording of the webinar can be accessed through ADAMS (ML13338A348). Please note that this recording will take additional time to download because of the large file size. The recording can be accessed on the second page of the PDF document by clicking on the forward arrow located on the bottom left corner.

Sincerely,

/RA/

Jamie Benjamin, Acting Chief Branch 4 Division of Reactor Projects Docket Nos. 50-255 and 72-007 License No. DPR-20

Enclosures:

1. Public Meeting Principal Attendees

2. Questions for the NRC Meeting on November 14, 2013 cc w/encls: Distribution via ListServTM DISTRIBUTION; See next page DOCUMENT NAME: Palisades Meeting Summary November 14 Webinar Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" =

Copy with attach/encl "N" = No copy OFFICE RIII E

RIII RIII RIII NAME SShah:rj JBenjamin DATE 12/13/2013 12/13/2013 OFFICIAL RECORD COPY

Letter to Entergy Nuclear Operations, Inc. from Jamie Benjamin dated December 13, 2013

SUMMARY

OF THE NOVEMBER 14, 2013, PUBLIC MEETING WEBINAR REGARDING INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

BASICS DISTRIBUTION:

Brett Rini RidsNrrPMPalisades Resource RidsNrrDorlLpl3-1 Resource RidsNrrDirsIrib Resource Cynthia Pederson Anne Boland Steven Orth Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPassessment.Resource@nrc.gov